Under what circumstances is a Carls franchisee allowed to combine Consumer Information received from CJR with personal information from another source?

According to Carls's 2024 Franchise Disclosure Document, a franchisee is generally prohibited from combining Consumer Information received from or on behalf of CJR (Carls Jr. Restaurants LLC) with personal information obtained from another source or collected from interactions outside the franchised restaurant's operation. However, there is an exception to this rule.

The franchisee can combine Consumer Information with other personal information if it is specifically allowed under applicable Privacy Law. This means that if a law, such as a state's consumer privacy act, explicitly permits such combining of data under certain conditions, the franchisee may do so, but only to the extent and under the conditions outlined in that law.

This stipulation places the onus on the Carls franchisee to stay informed about and compliant with all relevant privacy laws. It also implies that franchisees should seek legal counsel to fully understand their obligations and rights regarding consumer data. Carls retains the right to modify these restrictions with written notice, including adding privacy restrictions required by federal, state, or local privacy laws.